Policy on cookies and processing of personal data

1) Identity and contacts of the Data Controller

The Data Controller is Search On Media Group S.r.l. Since the Data Controller is located in Italy, there is no need to appoint a representative.

2) Contact details of data protection officer

The Data Controller has not appointed a data protection officer.

3) Methods of data processing

3.1 Cookies

Cookies are small text files sent by the website visited by the user to the browser, which stores and re-transmits them to the same site in the event of a new visit by the same user. Cookies allow us to collect information about how visitors use our website.

3.2 Technical cookies

Navigation, functional and session cookies: these allow the website to work properly. The use of so called session cookies (which are not permanently stored on the device of the user and are automatically deleted when the browser is closed) is strictly limited to the transmission of individual session identifiers. Session cookies are used in order to allow safe and efficient navigation on the website. Search On Media Group uses, for example:

Statistical cookies: The website uses statistical cookies made directly by the data controller or provided by third parties. In the latter case, suitable tools have been adopted to reduce their identifying capabilities, by also hiding significant portions of the controlled IP addresses. Furthermore, the use of these third-party statistical cookies has been subjected to contractual obligations that require third parties to use them exclusively to provide services, to store them separately and to not “enrich” them or “cross-reference” them with other information they have available. In any case, the Data Controller does not allow third-party suppliers to use cookies for purposes other than those listed above.

Browsing data and environmental variables: the IT systems and the procedures used to operate the web app site automatically acquire, during their normal functioning, some personal data relating to the navigation of the data subject, including environmental variables. This category of data includes, for example:

- The IP addresses of the computers or mobile devices used by users;

- The number of accesses;

- The pages displayed;

- The date and time the access occurred;

- The URL the browser was on before displaying our page;

- The type of browser;

- The operating system used.

3.3 Non-technical cookies

Profiling cookies: the site uses cookies provided by third parties.

4) Delete and disabling cookies

Since cookies are normal text files, they can be accessed using word processing programs. In any case, it is possible to configure your browser in order to prevent it from treating cookies.

- Delete/disable cookies with Firefox: http://support.mozilla.com/it/kb/Eliminare%20i%20cookie

- Delete/disable cookies with Edge: https://support.microsoft.com/it-it/help/4027947/windows-delete-cookies

- Delete/disable cookies with Chrome: http://support.google.com/chrome/bin/answer.py?hl=it&answer=95647

5) Data provided voluntarily by the user

Data spontaneously provided by the user by sending e-mails to our address may be acquired for the indicated purposes. In particular, in addition to the email address necessary to reply to the sender, any other kind of personal data contained in the message will be processed. Data collected in this way will be stored and processed exclusively for the purpose of continuing correspondence and will not be used for other purposes.

6) Purpose of processing and legal basis of processing

In relation to personal data processed by technical cookies in order to enable a proper use of the website; the communication of personal data is a contractual obligation; without this treatment the website wouldn’t function properly in accordance with terms and conditions of use, while it is optional in relation to non-technical cookies. In the latter case, failure to provide such data will only result in the impossibility of receiving a personalized service and the consent of the interested party, expressed in accordance with current legislation, constitutes the legal basis.

In relation to the data voluntarily provided by e-mail, the processing of personal data is not a contractual obligation, but a treatment based on the legitimate interest of the Data Controller to respond to the interested parties; without this processing it would not be possible to answer the requests made by the interested party. In this case, the processing of personal data allows us to respond to the requests of the interested parties. The legitimate interest of the Data Controller to respond to the interested parties constitutes the legal basis of the processing.

7) How to consent

The consent, whenever requested, can be given by clicking on a specific flagbox.

8) Source of personal data

The processing of data will only happen in the respect of the current information, using data collected by the website or by emails. Data from publicly accessible sources will not be processed. The personal data of the interested party will be processed. Particular data will not be processed pursuant to art. 9 of the GDPR.

9) Recipients and possible categories of personal data recipients

The recipients of your personal data may be: companies that offer services of an information society, including, in particular, those offering hosting services.

10) Data transfer

The Data Controller may intend to transfer personal data to a third country or to an international organization. Such subjects may be:

- Communication companies which conducts a communication activity on behalf of the Data Controller;

- Suppliers of services for the communication company;

- Controlled organizations and/or controllers.

The transfer of personal data to the mentioned subjects, if based in a third country or international organization, is carried out according to a decision of suitability of the European Commission, which evaluates how the third country, the territory or one or more specific sectors in the third country or the international organization ensure an adequate level of protection of the data subject’s rights. In the absence of such decision, the Data Controller – if deemed in any case appropriate – reserves himself the right to conclude specific separate agreements that oblige such subjects to adopt adequate security and also organizational measures, in order to offer appropriate guarantees related to the data subject’s rights. Data may be transferred in the following countries: U.S.A.

11) Retention period for personal data

Personal data processed and stored for all the purposes mentioned in this statement will be treated and stored for a period not exceeding 12 months starting from the day of the single collection. The Owner reserves the right, in any case, to request the interested party to renew their consent to the processing and / or to verify the consents already expressed.

12) Optional nature of consent and consequences in case of lack of consent

In relation to personal data processed through technical cookies in order to allow proper use of the web app, the communication of personal data is not a contractual obligation, but is based on the legitimate interest of the data controller, since the website wouldn’t be fully available without this treatment. However, it is considered optional in relation to non-technical cookies. In the latter case failure to communicate such data will only result in the impossibility of receiving a personalized service.

13) Rights of the data subject

Right to object: the data subject has the right to oppose, at any time and for reasons connected with their particular situation, to the processing of personal data concerning him/her, pursuant to Article 6, paragraph ,1 letters e) or f) of the GDPR, including profiling on the basis of these provisions. The Data Controller will refrain from further processing personal data, unless they are able to demonstrate the existence of compelling legitimate reasons for proceeding with the processing, which prevail over the interests, rights and freedoms of the data subject, or if they need to assess, exercise or defend one of their rights in court. If personal data is processed for marketing purposes, the data subject has the right to object at any time.

In case of opposition to the processing for direct marketing purposes, personal data will no longer be processed for these purposes. It is specified how the data subject's right to object to the processing of their personal data may also be exercised only partially, for example by opposing to the sending of promotional communications carried out through automated and / or digital tools, or to the sending of paper communications and / or the receipt of telephone communications.

If personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89, paragraph 1 of the GDPR, the interested party, for reasons connected with their particular situation, has the right to object to the processing of personal data concerning them, except in the case where the processing is necessary for the performance of a task of public interest.

14) Other rights

The Data Controller shall also inform the data subject about the existence the following rights:

- The right of access by the data subject: the data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and other specific information, pursuant to article 15 of the GDPR;

- The right to rectification: the data subject shall have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement, pursuant to article 16 of the GDPR;

- The right to withdraw the consent: the Data Controller shall have the obligation to erase personal data without undue delay where the grounds set out in article 17 of the GDPR apply.

- The right to restrict processing: the data subject shall have the right to obtain from the Data Controller restriction of processing where the grounds set out in article 18 of the GDPR apply;

- The right to data portability: the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to the Data controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller without hindrance from the Data Controller to which the personal data have been provided under the conditions set out in article 20 of the GDPR;

- The right to object to marketing communications: the contractor has the right to oppose, in every moment, free of charge, to the receipt of commercial communication.

15) Exercise of rights

The request to exercise the rights outlined here must be addressed directly to the Data Controller at the email address info@searchon.it or at the address: Via dei Mille, 3 40121 Bologna.

16) Accessibility

The policy on cookies and processing of personal data is accessible by the Data Controller on the website https://en.ibrida.io/. If expressly requested by the data subject, the information may also be given orally, provided that the identity of the data subject is proven, by means of a phone call.